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address was not changed in respondent's computer, and neither of
the returned notices of deficiency was reissued to the Brownway
address.
OPINION
This Court's jurisdiction to redetermine a deficiency
depends upon the issuance of a valid notice of deficiency and a
timely filed petition. Rule 13(a), (c); Monge v. Commissioner,
93 T.C. 22, 27 (1989). Section 6212(a) expressly authorizes
respondent, after determining a deficiency, to send a notice of
deficiency to the taxpayer by certified or registered mail. It
is sufficient for jurisdictional purposes if respondent mails the
notice of deficiency to the taxpayer's "last known address".
Sec. 6212(b)(1); Frieling v. Commissioner, 81 T.C. 42, 52 (1983).
If a deficiency notice is mailed to the taxpayer's last known
address, the notice is valid for purposes of section 6212 even if
not actually received by the taxpayer. King v. Commissioner, 857
F.2d 676, 679 (9th Cir. 1988), affg. 88 T.C. 1042 (1987);
Frieling v. Commissioner, supra at 52. The taxpayer, in turn,
has 90 days (or 150 days under circumstances not present herein)
from the date the notice of deficiency is mailed to file a
petition for a redetermination of the deficiency in this Court.
Sec. 6213(a).
There is no dispute in the instant case that the notices of
deficiency were mailed on March 22, 1993, and June 24, 1993,
respectively, and that the petition was filed on March 21, 1994,
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